JUDGMENT

Paripoornan, JJ.-Leave granted in all the special leave petitions.

2. These are all connected cases. The matter arises under the Companies (Profits) Surtax Act, 1964 (hereinafter referred to as the Act). The parties, in all the appeals are the same. The appellant in the appeals is "The State Bank of Patiala" and the respondent is the "Commissioner of Income Tax, Patiala". The Civil Appeals filed from Special Leave Petitions (C) Nos. 2392-95 of 1993 are the main cases. They relate to four assessment years - 1971-72, 1972-73, 1973-74 and 1975-76. The appellant-assessee set apart amounts as "reserve" for bad and doubtful debts" in all the years. A claim was laid that such sums qualified as reserves for the purpose of Rule 1(xi)(b) of the First Schedule and Rule 1 (iii) of the Second Schedule of the Act and such sums, representing reserves, should be included in the capital of the appellant for appropriate relief. The Income Tax Officer rejected the claim. In appeal, the Income Tax Appellate Tribunal allowed the plea of the assessee. The Income Tax Appellate Tribunal, by its detailed order dated 23.1.1980. upheld the plea of the assessee and held that the amounts set apart as